Privacy Policy
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Introduction
- We are committed to protecting the privacy of the Users of our Platform. This Privacy Policy explains what Personal Data we collect when you use the chatalternative.com website and the Chat Alternative mobile application, how and why we process it, with whom we share it, how long we keep it, how we protect it, and what rights and choices you have.
- The Company acts as the controller of the Personal Data processed through the Platform (or, where applicable law uses different terminology, as the "business" or equivalent responsible party), which means that we determine the purposes and means of that Processing.
- This Policy applies to every User of the Platform. By accessing or using the Platform, you acknowledge that you have read and understood this Policy. Where applicable law requires your consent for a specific Processing activity, such as the use of analytics Cookies or access to your camera and microphone, we ask for that consent separately, and you may withdraw it at any time.
- This Policy is a separate document from the User Agreement. The User Agreement governs your use of the Platform and your obligations as a User; this Policy governs the Processing of your Personal Data. Capitalized terms used in this Policy have the meanings given in the "Definitions" section below. Capitalized terms that are not defined in this Policy have the meanings given to them in the User Agreement.
- This Policy covers the collection, use, disclosure, international transfer, retention, and deletion of Personal Data, the measures we use to protect it, our Age Assurance practices, advertising, the use of Cookies, external links, notices for parents and legal guardians, and how to contact us.
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Definitions
- "Account" means the personal user account that a User must create in order to access and use the Platform, which is created by signing in through a Login Provider or through any other registration method that we make available.
- "Advertising Partners" means third-party advertising networks, advertisers, and advertising measurement providers that deliver or measure advertisements on the Platform.
- "Age Assurance" means, collectively, Age Gating and Continuous Age Assurance.
- "Age Estimation" means the automated, AI-based estimation of a person's apparent age from an image of that person's face.
- "Age Gating" means the layered set of checks that we apply when a User attempts to register an Account, described in the "Age Assurance at Registration (Age Gating)" section of this Policy.
- "Age Verification Provider" means Yoti, an independent third-party provider of age verification services, or any successor provider that we may designate.
- "Application" means the Chat Alternative mobile application for Android that we distribute through Google Play or other channels we authorize.
- "Ban Data" means the Personal Data that we retain in connection with a restriction of a User's access to the Platform, described in the "Personal Data We Collect" section under "Moderation and Ban Data".
- "Company", "we", "us", and "our" mean the legal entity that owns and operates the Platform under the Chat Alternative brand.
- "Continuous Age Assurance" means the ongoing and periodic checks that we apply after registration, throughout the lifetime of an Account, described in the "Continuous Age Assurance and Moderation" section of this Policy.
- "Cookies" means small text files and similar technologies (such as local storage and pixels) that are stored on your device when you use the Website, described in the "Cookies" section of this Policy.
- "CSAE" means Child Sexual Abuse and Exploitation, and "CSAM" means Child Sexual Abuse Material. These terms describe sexual content, conduct, or communication that involves, depicts, or targets any person under 18 years of age.
- "Login Provider" means a third-party identity service through which a User may create and sign in to an Account, such as Facebook, Google, or VK.
- "Minimum Age" means eighteen (18) years of age or, if the laws of the country, state, province, or other jurisdiction in which a User resides set the age of majority higher than 18 years, that higher age of majority.
- "Moderators" means the members of our staff and our authorized contractors who review Content, reports, and User behavior on the Platform and apply enforcement measures.
- "Neutral Age Screen" means a registration screen that asks a User to enter their date of birth or age without indicating the Minimum Age, without pre-filling an eligible value, and without otherwise suggesting which answer would grant access.
- "Personal Data" means any information that relates to an identified or identifiable natural person, including information that can be linked to such a person directly or indirectly, such as an identifier, an image of a face, or an IP address.
- "Platform" means, collectively, the Website and the Application, together with all related features, tools, and services that we provide.
- "Play Age Signals API" means the interface provided by Google Play that makes available to the Application an age range signal associated with the Google account used on an Android device.
- "Policy" and "Privacy Policy" mean this document, as amended from time to time.
- "Processing" means any operation performed on Personal Data, including collection, recording, storage, analysis, use, disclosure, transfer, and deletion.
- "Rules" means the rules of conduct on the Platform published at chatalternative.com/rules, as amended from time to time.
- "Service Providers" means third parties that process Personal Data on our behalf or provide services to us in connection with the Platform, such as hosting, content delivery, analytics, and payment providers.
- "Snapshot" means a still image captured automatically from a User's live video stream at intervals during a video chat session.
- "Underage Person" means any individual who has not reached the Minimum Age.
- "User", "you", and "your" mean any individual who accesses or uses the Platform, whether or not that individual has created an Account.
- "User Agreement" means the user agreement governing the use of the Platform, published at chatalternative.com/terms, as amended from time to time.
- "Website" means the website available at chatalternative.com, including its mobile version at m.chatalternative.com and all of its subdomains and pages.
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Account Requirement and Age Eligibility
- An Account is required to access and use the Platform. You cannot participate in video chats or use other core features of the Platform without an Account. Because an Account is created by signing in through a Login Provider, we necessarily process the Login Provider Data and Internal Data described in this Policy for every User. An Account is not a public profile: other Users cannot view your Account, your name, or the information that we receive from your Login Provider. The gender and location received from your Login Provider are used to select chat partners, and your date of birth or age is used for Age Assurance, as described in this Policy.
- The Platform is intended exclusively for adults. To create an Account or use the Platform, you must have reached the Minimum Age. This means that you must be at least 18 (eighteen) years of age or, if the laws of your country, state, province, or other jurisdiction of residence set the age of majority higher than 18 years, you must have reached that higher age of majority. The Platform is not designed for, directed at, or intended for use by Underage Persons.
- We do not knowingly collect Personal Data from Underage Persons. If we determine, through Age Assurance or otherwise, that Personal Data relates to an Underage Person, we terminate the associated Account and delete the Personal Data, except for the minimal Ban Data that we retain to prevent the person from regaining access and any data that we must retain to comply with legal obligations.
- Because we need to enforce the Minimum Age, we process certain Personal Data specifically for Age Assurance. The methods that we use are described in detail in the "Age Assurance at Registration (Age Gating)" and "Continuous Age Assurance and Moderation" sections of this Policy.
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Personal Data We Collect
We collect, process, retain, and transfer the following categories of Personal Data. The categories that apply to you depend on how you use the Platform (for example, through the Website or through the Application) and on the Login Provider that you use.
- Connection Data
- Source: your Internet connection.
- Data pieces:
- IP address;
- Country code and approximate location derived from the IP address (GeoIP);
- Connection type and Internet service provider.
- Client Data — Browser
- Source: your Internet browser, when you use the Website.
- Data pieces:
- Browser type and version;
- Operating system and platform;
- Browser plug-ins;
- List of available media devices (cameras and microphones);
- Screen resolution;
- Time zone;
- Browser language.
- Client Data — Device
- Source: your mobile device, when you use the Application.
- Data pieces:
- Device manufacturer and model;
- Operating system version;
- Internet connection information;
- Device identifiers made available by the operating system, which may include an installation identifier, serial number, IMEI, or phone number;
- Operating system language;
- Application version.
- Internal Data
- Source: our own systems.
- Data pieces:
- Internal user ID;
- Account creation date and last login date;
- Account status (active, restricted, terminated);
- Age Assurance status (whether, when, and by which method your age was confirmed).
- Login Provider Data
- Source: the Login Provider through which you sign in (Facebook, Google, or VK). The data pieces that we actually receive depend on the Login Provider, on the information that you have added to your Login Provider account, and on the privacy settings and permissions that you have configured with that Login Provider.
- Data pieces:
- User ID assigned by the Login Provider;
- Name;
- Gender;
- Date of birth or age range;
- Location (country code and city);
- Hometown;
- E-mail address.
- Age Assurance Data
- Source: you, your Login Provider, Google Play, the Age Verification Provider, and our own automated systems.
- Data pieces:
- Date of birth or age that you declare on the Neutral Age Screen;
- Age or age range received from your Login Provider;
- Age range signal received from the Play Age Signals API (Android only);
- The image of your face used for Age Estimation;
- Results of Age Estimation (estimated age or age range and whether it meets our threshold);
- Results received from the Age Verification Provider (whether or not you were confirmed to be 18 years of age or older and, where provided, the confirmed age band);
- Flags generated by automated analysis of chat messages that indicate language or patterns typical of Underage Persons.
- Videochat Data
- Source: you, during video chat sessions.
- Data pieces:
- Live video and audio stream (transmitted in real time to your chat partner and not recorded by us, except for Snapshots);
- Snapshots;
- Gender;
- Search country (the country of the chat partners that you want to be connected with);
- Chat messages.
- Moderation and Ban Data
- Source: you, other Users who submit reports, Moderators, and our automated systems.
- Data pieces:
- Reports and complaints (the internal user IDs of the reporting and reported Users, the reason for the report, and any screenshot attached by the reporting User);
- Snapshots and specific chat messages associated with a suspected or confirmed violation;
- Moderator decisions and the reasons for them;
- Type, start date, and duration of any restriction applied to an Account;
- Identifiers used to enforce restrictions, including the internal user ID, the Login Provider user ID, IP addresses, and device identifiers associated with the restricted Account.
- Settings Data
- Source: you, when you configure the Platform.
- Data pieces:
- Language settings;
- Translation settings.
- Payment Data
- Source: the payment systems through which you make purchases (Google Play and PayPal). We do not receive or store your full payment card number or bank account details.
- Data pieces:
- Transaction ID;
- Purchase token;
- Order ID;
- Product ID;
- Price and currency;
- Order date;
- Payer ID;
- Payer e-mail address;
- Payer name;
- Payer country.
- Correspondence Data
- Source: you, when you contact us by e-mail, through contact forms, or through the account deletion form.
- Data pieces:
- Your name;
- Your e-mail address;
- The content of your message;
- Message metadata (such as the date and time of sending);
- Attached screenshots and files.
- Usage Data
- Source: your Internet connection and browser, collected through the analytics and content delivery services described in the "Third-Party Services" section of this Policy.
- Data pieces:
- Google Analytics data (shortened IP address and Website activity, such as pages visited, click paths, and session duration);
- Cloudflare data (IP address and traffic logs).
- Advertising Data
- Source: our systems and the software of Advertising Partners (such as advertising SDKs in the Application or tags and Cookies on the Website). This category is collected only when advertisements are displayed on the Platform.
- Data pieces:
- Advertising identifier assigned by your device's operating system (such as the Google Advertising ID) or a Cookie-based identifier;
- IP address and approximate location derived from it;
- Device and browser information of the kind listed under Client Data;
- Information about the advertisements displayed to you and your interaction with them (impressions, clicks, and views);
- Your advertising consent and opt-out choices.
Please do not provide us with Personal Data of other individuals unless we explicitly ask you to do so, and do not share sensitive Personal Data (such as your home address, financial information, or identity documents) with other Users during video chats.
- Connection Data
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Purposes of Processing
We process the categories of Personal Data listed above for the following purposes:
- To create and manage Accounts and to authenticate Users at login:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Internal Data;
- Login Provider Data.
- To apply Age Gating at registration and prevent Underage Persons from creating Accounts:
- Connection Data;
- Client Data — Device;
- Internal Data;
- Login Provider Data;
- Age Assurance Data.
- To apply Continuous Age Assurance and to proactively identify Accounts of Underage Persons:
- Internal Data;
- Age Assurance Data;
- Videochat Data;
- Moderation and Ban Data.
- To moderate the Platform, handle reports, keep Users safe, and enforce the User Agreement and the Rules:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Internal Data;
- Videochat Data;
- Moderation and Ban Data.
- To enforce restrictions of access and to prevent restricted Users from regaining access:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Internal Data;
- Login Provider Data;
- Moderation and Ban Data.
- To connect Users with each other and allow them to engage in video chat:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Internal Data;
- Login Provider Data;
- Videochat Data;
- Settings Data.
- To display the Website, maintain connectivity with the Application, and ensure that the Platform functions correctly across browsers, devices, and Android versions:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Usage Data.
- To personalize the Platform to your preferences, including language settings, and to select chat partners on the basis of gender and country:
- Connection Data;
- Client Data — Device;
- Internal Data;
- Login Provider Data;
- Videochat Data;
- Settings Data.
- To process orders, payments, refunds, and payment-related inquiries:
- Connection Data;
- Internal Data;
- Payment Data.
- To communicate with you and respond to your inquiries, reports, and requests:
- Connection Data;
- Internal Data;
- Correspondence Data.
- To secure, administer, and protect our systems, including detecting and preventing fraud, abuse, and attacks:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Internal Data;
- Usage Data.
- To analyze how the Platform is used and to improve the Platform and the User experience:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Usage Data.
- To display advertising on the Platform, measure its performance, limit the frequency with which the same advertisement is shown to you, and detect advertising fraud:
- Connection Data;
- Client Data — Browser;
- Client Data — Device;
- Advertising Data.
- To comply with legal obligations, respond to lawful requests from public authorities, and report CSAM and other CSAE-related violations to the National Center for Missing and Exploited Children (NCMEC) and law enforcement:
- Any category of Personal Data, to the extent necessary for the specific obligation or request.
- To establish, exercise, or defend legal claims, whether in court proceedings or in administrative or out-of-court procedures, and to obtain insurance, manage risks, and obtain professional advice:
- Any category of Personal Data, to the extent necessary for the specific claim or purpose.
We do not sell your Personal Data, and we do not ourselves build advertising profiles of you. Where Advertising Partners deliver personalized advertising on the Platform, they do so only as described in the "Advertising" section of this Policy and subject to the choices available to you there.
- To create and manage Accounts and to authenticate Users at login:
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Legal Bases for Processing
Where the laws of your jurisdiction require us to have a legal basis for Processing, we rely on the following bases:
- Processing that is necessary to provide the Platform to you under the User Agreement, including creating and managing your Account, connecting you with other Users, processing your payments, and responding to your support requests.
- Processing that is necessary to comply with laws that apply to us, including laws that require us to prevent access by Underage Persons, to report CSAM, to retain payment records, and to respond to lawful requests from public authorities.
- Processing that is necessary for our legitimate interests or those of third parties, provided that those interests are not overridden by your interests or fundamental rights. Our legitimate interests include keeping the Platform safe and free from Underage Persons through Age Assurance and moderation, securing our systems, preventing fraud, abuse, and the evasion of restrictions, improving the Platform, establishing and defending legal claims, and managing our business risks.
- Processing for which applicable law requires your consent, including the use of analytics Cookies where required, access to your camera and microphone (which you grant through your browser or operating system permissions), and any other Processing for which we request your consent. You may withdraw your consent at any time, without affecting the lawfulness of Processing carried out before the withdrawal.
- Contextual advertising is based on our legitimate interest in financing the Platform. Personalized advertising, and the storage of or access to advertising identifiers and Cookies for advertising purposes, are based on your consent where applicable law requires it.
- Processing that is necessary to protect the life or physical safety of a User or of another natural person.
- We process images of your face solely for the purpose of estimating your apparent age as part of Age Assurance. Age Estimation does not identify you, does not compare your face against other individuals, and does not create a template used to recognize you across sessions. Where applicable law treats such images as biometric or otherwise sensitive Personal Data, we rely on the substantial public interest in protecting Underage Persons, on the legal obligations that apply to us, and, where required, on the explicit consent that you give when you enable your camera after being informed of this Processing.
- Certain Processing, including Age Assurance, is a necessary condition of using the Platform. If you object to or do not consent to that Processing, we are unable to provide the Platform to you.
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Age Assurance at Registration (Age Gating)
When you attempt to create an Account, we apply a multi-layered Age Gating process. Which layers apply to you depends on whether you register through the Website or the Application, on the Login Provider that you use, and on the age information available from those sources. Each layer can independently deny access, and a result obtained from a weaker signal may be confirmed by a stronger one before access is granted. Age Gating consists of the following layers:
- When you register through the Application, we request an age range signal from the Play Age Signals API. This signal reflects the age information associated with the Google account used on your device.
- When you register through a Login Provider (Facebook, Google, or VK) and you have specified your age or date of birth in your Login Provider account and shared it with us, we use that information.
- We may ask you to enter your date of birth or age on a Neutral Age Screen.
- We may perform Age Estimation on an image of your face captured through your camera.
- We may ask you to verify your age with the Age Verification Provider, in particular where the other layers have not confirmed that you have reached the Minimum Age. The Age Verification Provider determines, using its own methods and under its own privacy policy, whether you are 18 years of age or older. We receive only the outcome (whether or not you were confirmed to be 18 or older and, where provided, the age band); we do not receive identity documents or the images processed by the Age Verification Provider.
- If access is denied and you do not complete third-party verification, no functional Account is created. We may retain the identifiers associated with the attempt and the outcome of the Age Gating check as Ban Data in order to prevent repeated registration attempts by the same person.
- The outcome of Age Gating is stored as part of your Age Assurance Data so that you are not required to repeat the same check unnecessarily. Age Gating does not, however, exempt you from Continuous Age Assurance.
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Continuous Age Assurance and Moderation
Age Assurance does not end at registration. We check the age of Users periodically and continuously throughout the lifetime of their Accounts, and we proactively look for Accounts that belong to Underage Persons. Continuous Age Assurance is carried out through the following measures:
- The Platform is moderated by human Moderators 24 hours a day, 7 days a week, supported by automated tools. Moderators review the materials described below and apply enforcement measures in accordance with the User Agreement and the Rules.
- Complaints submitted by other Users about a video chat partner are reviewed by Moderators as part of continuous manual moderation. Complaints may include a screenshot attached by the reporting User.
- During video chat sessions, our systems automatically capture Snapshots from your live video stream at intervals. Snapshots are reviewed by Moderators as part of continuous manual moderation, both for compliance with the Rules and for the apparent age of the person on camera.
- Images of your face captured during video chat sessions are periodically analyzed using Age Estimation to re-estimate your apparent age. This check is repeated over time and is not limited to the moment of registration.
- Our systems detect whether a real, uncovered face is visible in your video stream. If you hide your face, cover it, replace it with an avatar or filter, or point the camera away from it, the system may prevent you from continuing the conversation until your face is visible again. The Platform is designed for communication between real people, and this requirement keeps interactions transparent. It also allows Moderators and Age Estimation to review whether Users appear to meet the Minimum Age.
- Automated filters analyze chat messages for words, phrases, topics, and patterns that are typical of messages written by Underage Persons, such as statements of an age below the Minimum Age or references to attending school. Accounts flagged by these filters are referred to Moderators for review and may be required to complete Age Estimation or third-party age verification.
- Our systems may automatically restrict the access of a User who receives multiple complaints from other Users within a short period of time. Such restrictions may be reviewed by Moderators.
- If Age Estimation indicates that your apparent age is insufficient, or if Moderators reasonably believe on the basis of Snapshots, complaints, or text pattern flags that you are an Underage Person, your access is denied. You may then verify your age with the Age Verification Provider. If the Age Verification Provider confirms that you are 18 years of age or older, access is restored. Otherwise, access remains denied, the Account is terminated, and the associated Personal Data is handled as described in the "Retention and Deletion of Personal Data" section.
- Accounts of Underage Persons may therefore be identified through AI-based Age Estimation, through automated filters and patterns applied to text messages that resemble messages of Underage Persons, through Moderator review of Snapshots, and through reports from other Users.
- If your access has been denied and you have reached the Minimum Age, you may also contact us as described in the "Contact" section of this Policy.
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Automated Decision-Making
- Certain decisions on the Platform are made by automated means without prior human involvement. These include the denial of access on the basis of an age range signal, a Login Provider age, or a declared age that is under 18; the denial of access on the basis of an Age Estimation result that does not meet our threshold; the pausing of a conversation when no face is visible in the video stream; the flagging of Accounts by text pattern filters; and temporary restrictions applied automatically after multiple complaints.
- These automated decisions may result in your being unable to create an Account, being unable to continue a conversation, or being temporarily restricted from using the Platform. We use them because the volume of live sessions on the Platform makes exclusively manual review impossible and because they allow us to act quickly to protect Users.
- We apply safeguards to these decisions, including a threshold for Age Estimation that includes a safety margin above the Minimum Age to reduce the risk of granting access to Underage Persons, review by human Moderators of flagged Accounts and automatic restrictions, and the possibility of completing verification with the Age Verification Provider.
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Disclosure of Personal Data
- When you take part in a video chat, your live video and audio stream and the chat messages that you send are disclosed to the User with whom you are connected. In addition, the Platform may establish a direct peer-to-peer connection between your device and the other User's device, which requires your IP address to be shared with that device. Your IP address is not displayed through the Platform's interface, but it could be revealed by third-party software running on the other User's device. We cannot control what other Users do with the information that you disclose to them.
- We share Personal Data with Service Providers that process it on our behalf or provide services to us, including hosting and infrastructure providers, Cloudflare (content delivery and security), Google (analytics, Google Play distribution and billing, and the Play Age Signals API), PayPal (payments), and providers of e-mail and support tools. Service Providers receive only the Personal Data necessary for the services that they provide to us, are bound by contractual obligations of confidentiality and data protection, and are described further in the "Third-Party Services" section of this Policy.
- Login Providers and the Age Verification Provider process your Personal Data as independent controllers under their own privacy policies, as described in the "Third-Party Services" section of this Policy.
- Where advertisements are displayed on the Platform, Advertising Partners collect Advertising Data directly from your device through their SDKs, tags, or Cookies, as described in the "Advertising" section of this Policy. Under certain United States state privacy laws, this collection may qualify as "sharing" of Personal Data for cross-context behavioral advertising, from which you may opt out as described in that section.
- Moderators, who may be our employees or contractors bound by confidentiality obligations, have access to the Videochat Data, Age Assurance Data, and Moderation and Ban Data that they need in order to review Content and apply enforcement measures.
- We may disclose Personal Data where we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or a request from a public authority; to enforce the User Agreement and the Rules; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of the Company, our Users, or the public.
- Where we obtain actual knowledge of, or reasonably suspect, CSAM, CSAE, or other serious illegal activity, we may disclose the relevant Personal Data, including Snapshots, chat messages, Account information, and identifiers, to the National Center for Missing and Exploited Children (NCMEC) and to law enforcement authorities in the United States and other relevant jurisdictions, and we preserve the related data as required by law.
- We may disclose Personal Data to our insurers and professional advisers to the extent reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims.
- If we are involved in a merger, acquisition, reorganization, financing, or sale of all or part of our business or assets, Personal Data may be disclosed to the parties involved and transferred as part of that transaction, subject to the continued application of this Policy or of a policy that provides no less protection.
- We may share information that has been aggregated or de-identified so that it can no longer reasonably be used to identify you, for any purpose.
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Third-Party Services
- When you sign in through Facebook, Google, or VK, the Login Provider authenticates you and transmits to us the Login Provider Data described in this Policy. The Login Provider also learns that you are using the Platform. The Login Provider's Processing of your Personal Data is governed by its own privacy policy: Meta Platforms (Facebook) at facebook.com/privacy/policy, Google at policies.google.com/privacy, and VK at vk.com/privacy. You can control which information the Login Provider shares with us through the privacy and application settings of your Login Provider account.
- The Application is distributed through Google Play, operated by Google LLC. Google Play processes your Personal Data for the download and updating of the Application, for in-app purchases and subscriptions, and for the Play Age Signals API. Google's Processing is governed by its privacy policy at policies.google.com/privacy.
- When you choose to verify your age, you are redirected to the Age Verification Provider, Yoti, which processes the Personal Data needed for verification (which may include an image of your face or an identity document, depending on the method you choose) under its own privacy policy at yoti.com/privacy. We receive only the outcome of the verification as described in this Policy.
- We use Google Analytics, a web analytics service provided by Google Ireland Limited, to understand how the Website is used and to improve it. Google Analytics uses Cookies to collect information about your use of the Website, including your browser type, operating system, the previous site visited, a shortened IP address, and the time of the server request, which may be transferred to and stored on Google servers in the United States. Google uses this information on our behalf to evaluate your use of the Website and to compile reports on Website activity. Google Analytics retains this data for the period configured in our Google Analytics account, which does not exceed 14 months. Where required by law, Google Analytics is activated only with your consent, which you may withdraw at any time. You can also prevent the collection of your data by Google Analytics by installing the browser add-on available at tools.google.com/dlpage/gaoptout. Further information is available in Google's privacy policy at policies.google.com/privacy.
- We use the content delivery network and security services of Cloudflare, Inc. to deliver the Website efficiently through regional servers and to protect it against threats and bandwidth misuse. Your requests to the Website pass through Cloudflare's servers, which collect statistical access data including IP addresses, the pages requested, browser type and version, operating system, referrer URL, and the time and frequency of access, and which use Cookies for security verification. Cloudflare deletes most of this data within 24 hours and retains only anonymized data for longer periods. Further information is available in Cloudflare's privacy policy at cloudflare.com/privacypolicy.
- Payments made through the Website may be processed by PayPal, which processes your Personal Data under its own privacy statement at paypal.com/us/legalhub/privacy-full. We receive from PayPal only the Payment Data described in this Policy.
- The Website may include a Facebook "Like" button and an X (formerly Twitter) publish button. These widgets establish a direct connection between your browser and the servers of the respective social network. If you are signed in to the social network while visiting the Website, the social network may associate your visit with your account, and any interaction with the widget is transmitted directly to and stored by the social network. To prevent this, sign out of the social network before visiting the Website. Further information is available in Facebook's privacy policy at facebook.com/privacy/policy and in X's privacy policy at x.com/privacy.
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Advertising
- We may display advertisements on the Website and in the Application. Advertisements may be delivered by us or by Advertising Partners. The Personal Data processed for this purpose is described under "Advertising Data" in the "Personal Data We Collect" section of this Policy.
- Advertising Partners may use advertising SDKs, tags, Cookies, and advertising identifiers to deliver advertisements, to measure how often an advertisement has been displayed and clicked, to limit the frequency of advertisements, and to detect fraud. In doing so, Advertising Partners act as independent controllers of the Personal Data that they collect, under their own privacy policies. Where advertisements are delivered by an Advertising Partner, we identify that Advertising Partner in the "Third-Party Services" section of this Policy, together with a link to its privacy policy and to the opt-out tools that it provides.
- Advertisements on the Platform may be contextual, meaning that they are selected on the basis of the page or screen on which they appear and general information such as your language and approximate location, and not on the basis of a profile of you. Where applicable law requires your consent for personalized advertising or for the storage of or access to advertising identifiers and Cookies, we display personalized advertising only if you have given that consent through the consent options provided on the Website or in the Application, and you may withdraw it at any time through the same options.
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You can control advertising-related Processing in the following ways:
- Where consent options are provided on the Website or in the Application, you can decline or withdraw consent to personalized advertising at any time.
- On Android devices, you can reset or delete your advertising identifier and opt out of ads personalization in the privacy settings of the operating system.
- On the Website, you can block or delete advertising Cookies as described in the "Cookies" section of this Policy.
- Where required by law, we treat browser-based opt-out preference signals, such as Global Privacy Control, as a valid request to opt out of the sharing of your Personal Data for cross-context behavioral advertising.
- Where the User Agreement and the description of a Paid Service so provide, you may purchase a Paid Service that removes or reduces advertising.
- Because the Platform is intended exclusively for adults, advertising on the Platform is directed at adults, and we do not knowingly permit advertising to be personalized to Underage Persons.
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Retention and Deletion of Personal Data
- We do not keep Personal Data for longer than is necessary for the purposes for which it is processed, as described below, unless a longer period is required by law.
- Internal Data, Login Provider Data, Settings Data, and the outcome of Age Assurance checks are retained for as long as your Account exists. Once you delete your Account, it is deactivated immediately, and this data is removed from our servers within 30 days.
- We do not keep a complete log of your text messages. Incoming and outgoing messages are not stored as part of your Account and cannot be retrieved or restored. Specific messages are retained only where they are flagged by text pattern analysis pending Moderator review, or where they form part of Ban Data.
- Live video and audio streams are transmitted in real time and are not recorded or stored by us.
- Snapshots and images of your face captured for Age Estimation and moderation are retained only for the short period necessary to perform Age Estimation and any related Moderator review, after which they are deleted, unless they form part of Ban Data or must be preserved for legal purposes.
- We do not keep a general record of your conversations, including whom you communicated with and when.
- Ban Data is retained for as long as is technically necessary to enforce the corresponding restriction. Once a temporary restriction expires, the images associated with it are deleted, but a record of the restriction itself (its type, reason, and duration) is retained so that repeated violations can be recognized and enforcement remains consistent. Where a restriction is permanent, including restrictions applied because a person was determined to be an Underage Person or violated our zero-tolerance policy toward CSAE and CSAM, the identifiers needed to prevent the person from regaining access are retained for as long as the restriction remains in force.
- Payment Data is retained for the period required by applicable tax, accounting, and consumer protection laws.
- Correspondence Data is retained for as long as necessary to handle your inquiry and for a reasonable period afterwards for record-keeping and the establishment or defense of legal claims.
- Usage Data is retained for the periods set by the relevant Service Providers as described in the "Third-Party Services" section of this Policy.
- Advertising Data that we hold ourselves is retained only for as long as necessary to deliver and measure advertising and to detect advertising fraud. Advertising Partners retain the Advertising Data that they collect in accordance with their own privacy policies.
- Notwithstanding the above, we may retain Personal Data for longer where this is necessary to comply with a legal obligation, to preserve evidence of CSAM, CSAE, or other serious illegal activity for law enforcement, to protect the vital interests of any person, or to establish, exercise, or defend legal claims.
- If you use the Application, you can delete your Account through the settings of the Application. Any User can also request deletion of their Account and associated Personal Data through the account deletion form at chatalternative.com/account-deletion, which asks you to sign in through your Login Provider so that we can verify that the request comes from the Account holder. After verification, we process the request in accordance with this Policy and applicable law.
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Protection of Personal Data
- We implement appropriate technical and organizational measures to protect Personal Data against accidental or unlawful loss, destruction, alteration, unauthorized access, unauthorized disclosure, and other unlawful forms of Processing.
- These measures include encryption of data in transit between your device and our servers using TLS (SSL) technology, hosting of our databases in secure data centers, access controls that limit access to Personal Data to authorized personnel who need it to perform their duties, and contractual confidentiality obligations for our staff, Moderators, and Service Providers.
- No method of transmission over the Internet or of electronic storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security, and you are responsible for keeping the credentials of your Login Provider account confidential.
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Cookies
- A Cookie is a small text file containing an identifier, consisting of a string of letters and numbers, that a web server sends to your browser and that your browser stores on your device. Each time your browser requests a page from that server, it sends the identifier back, which allows the server to recognize your browser.
- "Persistent" Cookies remain stored on your device until their set expiry date, unless you delete them earlier. "Session" Cookies are temporary and expire when you close your browser.
- Cookies do not usually contain information that directly identifies you, but the Personal Data that we hold about you may be linked to the information stored in and obtained from Cookies.
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We use Cookies on the Website for the following purposes:
- To recognize you when you visit and navigate the Website, keep you signed in, remember your settings, and ensure that the Website functions correctly and securely. These Cookies are strictly necessary for the Website to operate.
- To understand how the Website is used and how it performs, so that we can identify trends and improve the Website. These Cookies are set by Google Analytics, as described in the "Third-Party Services" section of this Policy, and, where required by law, are used only with your consent.
- Where advertisements are displayed on the Website, Advertising Partners may set Cookies to deliver and measure advertisements, as described in the "Advertising" section of this Policy. Where required by law, these Cookies are used only with your consent.
- Some Cookies are set by Service Providers, Advertising Partners, and social networks rather than by us. These include Cookies set by Google Analytics, Cloudflare, any Advertising Partners, and the social media widgets described in the "Third-Party Services" section of this Policy, and they are governed by the privacy policies of those providers.
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You can manage Cookies through your browser:
- Most browsers allow you to refuse new Cookies, to be notified when a Cookie is set, and to delete Cookies that have already been stored. The method for doing so depends on your browser and its version; consult your browser's help documentation.
- Blocking all Cookies has a negative impact on the usability of many websites. If you block Cookies on the Website, you may not be able to sign in or use all of its features.
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External Links
- The Platform may contain links to third-party websites, applications, and resources that we include to enhance your experience and to provide additional information.
- Although we make reasonable efforts to link only to reputable resources, we do not control third-party websites and are not responsible for their content, their security, or any action that you take on them.
- Any Personal Data that you provide to a third-party website is governed exclusively by that website's own privacy policy, which you should review before providing it. We are not responsible for Personal Data that you share with third-party websites.
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Notice for Parents and Legal Guardians
- The Platform is intended exclusively for adults who have reached the Minimum Age, and Underage Persons are prohibited from using it, regardless of parental consent or supervision. The Application is published on Google Play with an age rating of 18+ and is declared under Google Play's target audience and content settings as an application that is not designed for children (this is the designation used by Google Play itself). These designations allow parental control tools to correctly recognize and block the Application on devices configured for a person under 18.
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Although we apply Age Assurance to enforce the Minimum Age, we encourage parents and legal guardians to supervise the online activity of Underage Persons in their care, to protect their Personal Data, and to use the parental control tools built into the devices and app marketplaces that those persons use. The following official guides explain how to set up such tools:
- Windows: Set up parental controls with Microsoft Family Safety.
- macOS: Apple family features, Screen Time, and content restrictions.
- Android: Get started with Google Family Link.
- Google Play: Set up content restrictions on Google Play, which allows blocking applications by age rating.
- If you believe that an Underage Person in your care has created an Account, accessed the Platform, or provided Personal Data to us, please contact us immediately at the e-mail address given in the "Contact" section of this Policy, providing enough information for us to locate the Account (such as the Login Provider used and the associated e-mail address). We will terminate the Account, delete the associated Personal Data as described in the "Retention and Deletion of Personal Data" section, and take reasonable measures to prevent the person from regaining access.
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Notice for Persons Who Have Not Reached the Minimum Age
- The Platform is for adults only. If you are under 18 years of age, or if you have not reached the age of majority in your country where that age is higher than 18, you are not allowed to use the Platform or to create an Account.
- If you have not reached the Minimum Age, please stop using the Platform immediately, do not provide us with any Personal Data, and do not attempt to bypass our age checks. If you have already created an Account, please ask a parent or legal guardian to contact us so that we can remove the Account and the associated Personal Data.
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Reporting Security Vulnerabilities
- The security of Personal Data is a priority for us. If you identify a potential security or privacy vulnerability in the Platform, please report it to us by e-mail at [email protected] with a detailed description of the issue. We will contact you if we need additional information. Please do not exploit the vulnerability or access Personal Data of other Users beyond what is strictly necessary to demonstrate the issue.
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Amendments
- We may revise this Policy from time to time, including to reflect changes in the Platform, in our Processing practices, or in applicable law. The current version is published on the Website and supersedes all previous versions. Amendments take effect from the moment the revised text is published on this page, unless a later effective date is stated.
- We may, but are not obligated to, notify Users of material amendments through the Platform or by other means. We recommend that you review this page periodically to stay informed about how we process your Personal Data.
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Contact
- If you have questions about this Policy, wish to exercise your rights, or wish to report an Account of an Underage Person, please contact us by e-mail at [email protected]. Messages sent to this address that are not related to privacy or Personal Data may not be answered.
- Deletion requests may also be submitted through the account deletion form at chatalternative.com/account-deletion.
- For questions about the User Agreement, the Rules, or other matters relating to the Platform, please use the contact details given in the User Agreement.